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Home My WebLink About2023-08-04 PD letter Susan Lebo, SHPD Mitchell D. Roth moo`...... Zendo Kern Mayor , Director Lee E. Lord Jeffrey W. Darrow Managing Director w �� Deputy Director •f,TE of H^ * West Hawaii Office East Hawaii Office 74-5044 Ane Keohokalole Hwy • • 101 Pauahi Street,Suite 3 Kailua-Kona,Hawaii 96740 County of Hawa1� 1 Hilo,Hawaii 96720 Phone(808)323-4770 Phone(808)961-8288 Fax(808)327-3563 PLANNING DEPARTMENT Fax(808)961-8742 August 04, 2023 Susan Lebo, Ph.D. Archaeology Branch Chief DLNR-SHPD 601 Kamokila Blvd., Rm. 555 Kapolei, HI 96707 Dear Ms. Lebo: SUBJECT: Change of Zone Amendment Application (PL-REZ-2022-000033) Applicant: Kona Three,LLC Request: Ten-Year Time Extension to Comply with Condition I (Complete Construction of Phase I) and Condition N (Roadway Standards) Tax Map Keys: (3) 7-6-021:016 & 017; por.Holualoa Hui Lands, Holualoa 1,2, & 3,North Kona,Hawai'i At the request of the Leeward Planning Commission (LPC), the Hawaii County Cultural Resources Commission (CRC) was consulted for their review and recommendation on the proposed project's impacts on cultural and historic resources found within the project area. Between March 8, 2023 and July 12, 2023, the CRC held four public meetings and a site visit to the project area. Based on the preceding, the CRC cited previously undocumented resources (Holualoa Trail and petroglyph) as well as other possible significant cultural and historic features not previously identified and is of the opinion that due to the historic and cultural significance of the property, the project will likely have a substantial impact on historic assets. Furthermore,the CRC recommended that the project area be preserved in perpetuity, however, if this is infeasible, the CRC recommends further documentation of lineal descendant and kama`a—ma knowledge of the natural and cultural resources of the project area, inclusive of trails. Finally, the CRC recommends that, in consultation with the community, the applicant amend the current devlopment plan to include larger open space areas that integrate and protect natural, historical, anc cultural features of the landscape. The CRCs recommendation and site visit report can be found in the enclosed July 17, 2023 letter to the LPC. www.plannina.hawaiicounty.aov Hawaii County is an Equal Opportunity Provider and Employer plannina(u),hawaiicounty.aov Susan Lebo, Ph.D. Archaeology Branch Chief DLNR-SHPD August 04, 2023 Page 2 Based on the preceding information, I am writing to determine if DLNR-SHPD would like to expand the parameters of its Chapter 6E-42 Historic Preservation Review and/or amend any comments, findings, or requirements of the applicant under that statute. For your convenience, enclosed are the most recent correspondences between DLNR-SHPD and the County/Applicant. Finally, this matter is scheduled to be taken up by the LPC during their September 21, 2023 hearing and we are requesting that you and/or another DLNR-SHPD representative attend the hearing via Zoom to address LPC Commissioner questions. Please confirm your availability at your earliest convenience. Should you have any questions,please feel free to contact me at (808) 961-8158. Sincerely, J�ffYe y W. Dawow August 04,2023:07:08 AM JEFFREY W. DARROW Deputy Planning Director CRK: mads P\wpwin60\PC\2023 PD Reports for Supervisor&Director\Kona Tbree SHPD Letter\LLeboSHPDKonafbreeREZAmend.docx Enclosures: CRC RECOMMENDATION LTR(7.17.2023) 3-7-6-021_2018-01123_1805SN05 ARCHY_6E42 AIS ACCP(5.31.2018) 3-7-6-021_2019-01323_1908JC03_HC_13-300-33_BTP_DRAFT_ACCP(8.19.2019) 3-7-6-021_2020-01241_2010NM09_ARCHY_6E42_PP_REV_REQ(10.30.2020) 3-7-6-021_2020-00727 2020PR32834_2110NM05 ARCHY 6E42 AIS ACCP(10.15.2021) RTC SHPD Review Draft PP-I (6.15.2022) cc via email w/enclosures: Leeward Planning Commission Daryn Arai, Land Use Planning Consultant for Kona Three, LLC DeVera, Ashley From: Planning Cultural Resources Commission Sent: Thursday, July 20, 2023 9:56 AM To: Planning Internet Mail Cc: Planning Cultural Resources Commission; Kern, Zendo; Jackson, Maija; Daryn Arai Subject: KONA THREE LLC (PL-CRC-2023-000002) CRC Final Recommendation to LPG Aloha, Linked below is the Cultural Resources Commission's comments and recommendations regarding the change of zone amendment application (PL-REZ-2022-000033) at the Leeward Planning Commission's request. Please forward this letter to the members of the Leeward Planning Commission for their consideration. 2023-07-12 CRC to LPC F`nPl Pecommendation Letter No hard copy to follow. Mahalo, Cultural Resources Commission Staff Main Line:808-961-8288 Bcc: CRC Members *1 County of Hawai'i Zoning& Subdivision Code Update Project Website: COHcodeupdatexom 1 Mitchell D. Roth ....... 4 ' cP:�� •""+1 Aaron Spielman, Chair �fc�ror I. •' alie ICurashima, Vice Chair •� Matthew Clark Desmon Haunica .�'air•ofh� r� Kilohana Hirano - - Roberta"Ku'ulei- Keakealani Kealolianuiopuna Kinney County of Hawaii Nicole Lui PLANNING DEPARTMENT Scott Mahoney CULTURAL RESOURCES COMMISSION Aupuni Center - 101Pauahi Street, Suite 3 - Hilo, Hawaii 96720 Phone(808)961-8288 * Fax(808)961-8742 July 17,2023 Barbara DeFranco,Chairperson Leeward Planning Commission 101 Pauahi St., Suite 3 Hilo,HI 96720 Dear Ms. DeFranco: SUBJECT: Change of Zone Amendment Application (PL-REZ-2022- 000033) Applicant: Kona Three,LLC Request. Ten -Year Time Extension to Comply with Condition i (Complete Construction of Phase 1) and Condition N(Roadway Standards) Tax Map Key: (3) 7- 6- 021: 016 and 017: North Kona, Hawaii The Leeward Planning Commission,at its duly held public hearing on December 15, 2022,considered the above -referenced application. The subject properties are located along the east (mauka)side of the Quern K.a'ahumanu Highway at its junction with Kuakini Highway and between Pualani Estates subdivision to the north and Kona Vistas to the south, portion of Hblualoa Hui Lands, Holualoa 1, 2, and 3,North Kona, Hawai'i. The Commission voted to dcfcr its decision until the County of Hawai'i Cultural Resources Commission (CRC)had the opportunity to review the project. • On March R, 2023, the CRC held an official meeting according to the provisions of Chapters 91 and 92 Hawai'i Rcviscd Statutes and Chapter 2, Article 44 of the Hawaii County Code, to deliberate the subject request;consider design review, comment(s) and recommendation(s)for Kona Three LLC (PL-REZ-2022-000033), In accordance with HRS 92-5.5, the CRC formed a Permitted Interaction Group(PIG) subcommittee to further review the project and a site visit occurred on March 23, 2023, at 10:00 a.m. The subcommittee subsequently created a site visit report(the Report). • On May 10,2023, the CRC heard the Report from the PIG subcommittee regarding the March 23, 2023, site visit conducted for the Kona Three project. • On June 21,2023, the CRC held discussion of recommendations and opinions of the project (based on the site visit,public testimony, the records, and documents on file includinrg archaeological reporr,;,mbrnitted) and made motions in culmination of their review;the communication was drafted by staff. This draft was presented to the CRC on July 12,2023, at a regular CRC meeting. www.cohntanninWent-coin Htmru i C'o�rnrt is an Fqad OpportunitY Provider andErnplQyer ntanningfdco.hawaii.hims Barbara DeFranco, Chairperson Leeward Planning Commission Page 2 July 17, 2023 In accordance with Hawaii County Code Section 2-44 and the Rules of Practice and Procedure for the Cultural Resources Commission, the review,recommendations,and opinions on the project are as follows-, After considering the cultural and historic resources on the property including the undMlniented Holualoa Trail and petroglyph and how it relates to H61ualoa, as vvell as other possible significant cultural historic features not previously identified,the CRC's opinion of the project's impact to historical assets is that this project will likely have a substantial impact on historic assets_ The following Cultural Resources Commission's opinions and recommendations are hereby transmitted for your consideration in execution of the action before you. 1. Rue to the historic and cultural significance of the property,the CRC recommends that the property be preserved in perpetuity.. In the event that this is infeasible, the CRC recommends the following conditions be required to be completed prior to any development permit approvals by the County. a. In order to be integrated into the development design, the CRC recommends further documentation of lineal descendant and kama`aina knowledge of the natural and cultural resources of the project area, inclusive of trails. b. That the applicant, in consultation with the community,amend the current development plan to include larger open space areas that more sensitively integrate and protect the natural,historical,and cultural features of the landscape, including trails and other cultural sites, as well as natural features of the terrain such as drainage channels,and native plants. Mahalo for your consideration of the CRC's review. If you have any questions concerning this matter, please contact Kevin Sullivan at kevin_sullivanL(r`hawaiicouniy_20v, Sincerely, Aaror J.5p6e man(Jul 18,202315:31 LEST) Aaron J. Spielman, Chairman Cultural Resources Commission KS:klt 1',COH01�planninglpubliclwpwin6OCultural_.Resources Corninission%ProjectsXcna Three LLC Tv1K 76021016&017(PL-CRC-2D23- 006002)\2023-07-12 CRC to L.PC Final Recommendation LertcrAocx cc via email: Daryn Arai, Representative for Kona Three LLC Zendo Kern, Planning Director Cultural Resources Commissions Enclosure: Permitted Interaction Group Report Cultural Resources Commission 5/10/2023 Project: Ilona Three LLC. Attu CRC—Nicole Lui, Kuulei I�eakealani,Aaron Spielman; Guest of Ref No.: PL-CRC-2022-OOOC�02. CRC —Lehua Kamaka; Kona.Three LLC Site Visit: 3/23/2023 Jbursday). — Richard Wheelock, Robert Williams, Location: Holualoa Hui Lands, Iblichael Matsukawa (counsel), Glenn Holualoa 1,2, & 3,North Kona, Hawaii. Escort (archaeologist),DarI Arai (planning consultant); SHPD — Sean Time: 10.15a— I A5p. Naleimaile, Nicole Mellow,Na Ala Hele (State) —Jackson Bauer, Rick Gmirkin, Loke Davis. Re: Permitted Interaction Group Report on Site Visit to the Subject Parcel. Outline Notes: 1. Introductions. 2. Opening Pule. 3. Archaeologist review of the LCA& overlaps with different maps. 4. Access to the subject parcel was through a different parcel mauka. A makai access does not seem to have been established. Unclear where construction access will be. 5. Railroad boundaries/berms. 6. Portion of site walls heading mauka, discussion of mauka trails near Holualoa Hotel. 7. ll'Iauka boundaries,wall aligravients, stream bed that runs through subject parcel. 8. Site walls and trail makai of railroad, discussion on these elements and history, Kuulei's mana'o, Nicole's mana'o. Daryn Arai stated that the applicant has been working for seven years on this request for a time extension. This area appears to have been used as a trail during and before the historical ranching period and might need to be considered in light of the Highways Act. 9. Walked further makai along the same trail makai of the railroad. Site walls to north and south of trail have different characteristics and states of repair. South wall more intact, north wall more scattered. South wall appears to use somewhat smaller rocks. North wall has enormous rocks still in place. Rick Gmi.rkin mentioned haka haka stones and the appearance of what might have been a holua sled at one time. 10. Crossed south of this same trail and walked through an area that is known to have been bulldozed. Scattered rocks (remnants of terraces?) and generally sloped terrain that is less defined than the trail to the north bounded by the site walls. 11. Walked mauka through what appears to be a terraced area and arriving at what feels very much like a homesite, at the level grade under the large tree. Nicole discovered a w()Irki_ng poliaku and shared with the archaeologist to record and preserve with an ancestral descendant. 12. Walked mauka to railroad and then south to the next section of site walls and trail. 13. Nicole shared insights at this southern trail area bounded by lava rock walls. Request to archaeologist to preserve this feature in place to mare part of the proposed colninunity. Unclear that this feature is recorded in the applicant's documentation. 14. Break/snack time. 15. Closing pule and mele. Lessons Learned. 1. Establish protocols for fixture PIG site visits (pule, introductions, meeting, closing). 2. Important for all Owners to attend entire PIG site visits. 3. Mr. Wheelock suffered injuries towards the end of the site visit when navigating the access point to the subject parcel via ladder tied to a hog-trap over a lava rock wall. Access for PIG site visits must be safe for all attending parties. 4. Time should be allotted for access to the entire property for all PIG members. 5. Visiting group should move as one party throughout the property. SUZAN.NE D.CASE DAVID Y.IGE �',` - CHAIRPERSON GOVERNOR OF :"F C-,.....•yq BOARD OF LANDANDNATURALRESOURCES HAWAII J,(P�'a VJ COMMISSION ON WATER RESOURCE MANAGEMENT 5g ROBERTK MASUDA MST DEPUTY arwj N I - JEFFREY T.PEARSON,P.E. Ot �tG »NNII .,nf f DEPUTY DIl CTOR-WATER 3`� JJJ '•,•�/j- ''xx^� AQUATICRE NO CES BOATINQUATIC EANRECREATION n BUREAU OF CONVEYANCES p h� „ _Y.�, COMMISSION ON WATER RESOURCE MANAGEMENT CONSERVATION AND COASTAL LANDS CONSERVATION AND RESOURCES ENFORCEMENT STATE OF HAWAII ENGINEERING FORESTRY AND WILDLIFE 'ateOf DEPARTMENT OF LAND AND NATURAL RESOURCES HIE ISLA PRESERRAT ON ❑f�arya� KAHOOLAWE ISLAND RESERVE COMMISSION LAND STATE HISTORIC PRESERVATION DIVISION STATE PARRS KAKUHIHEWA BUILDING 601 KAMOKILA BLVD,STE 555 KAPOLEI,HAWAII 96707 May 31,2018 IN REPLY REFER TO: Rick Wheelock Log No. 2018.01123 181 Kalaniana`ole Street Doc.No. 1805SN05 Hilo,Hawaii 96720 Archaeology Email richardeastwestrealty.org Dear Mr.Wheelock: SUBJECT: Chapter 6E-42 Historic Preservation Review— Archeological Inventory Survey of 5.0 Acres in Holualoa Holualoa 1st Ahupua`a,North Kona District,Island of Hawaii TMK: (3)7-6-021:017 por. This letter provides the State Historic Preservation Division's (SHPD's) review of the revised report titled Archaeological Inventory Survey Report for 5.0 Acres Located in Holualoa I"Ahupua`a, North Kona, Hawai`i Island, Hawai`i[TMK: (3) 7-6-021:017 por.] (Escott and Escott, revised May 2018). Revisions to the report were requested via email on May 13, 2018 (Susan Lebo [SHPD] to Glenn Escott [Scientific Consultant Services, Inc. (SCS)])and SHPD received the revised report on May 18,2017. SCS conducted the archaeological inventory survey (AIS) at the request of the landowner, Kona Three, LLC. The AIS was conducted in support of a County of Hawaii permit application for proposed development of the property. The AIS covered a 5.0-acre portion of the 30.901-acre parcel. The fieldwork included a 100%pedestrian survey of the entire project area.Ground visibility was fair to poor. Subsurface testing was conducted at several features. The AIS documented twenty-two newly identified historic properties(Table 1).The sites include a pre-and/or early post-Contact lava tube burial, pre- and/or early post-Contact agricultural terraces, and post-Contact walls and enclosures associated with agriculture and/or ranching,and a post-Contact railroad berm. Table 1. Summary of Sites Documented in AIS Site#50-10-37- Type Function Age 30591 Agricultural Complex Agriculture Pre-to Post-Contact 30592 Railroad and Berm Transportation Historic 30593 Lava Tube Burial Pre-to Early Post-Contact 30594 Agricultural Complex Agriculture Pre-to Post-Contact 30595 Rock Wall Ranching Historic 30596 Possible Hearth Food Preparation Historic 30597 Rock Wall Ranching Historic 30598 Rock Wall Agriculture/Ranching Pre-to Post-Contact 30599 Platform&Enclosure Ranching/Agriculture Historic 30600 Terrace Agriculture Historic 30601 Rock Wall Ranching Historic 30602 Enclosure Ranching/Agriculture Historic 30603 Enclosure Ranching/Agriculture Historic Mr. Wheellock May 31,2018 Page 2 Site#50-10-37- Type Function Age 30604 Agricultural Complex Agriculture Pre-to Post-Contact a 30605 Rock Wall Ranching/Agriculture Pre-to Post-Contact 30606 Rock Wall Ranching/Agriculture Pre-to Post-Contact 30607 Agricultural Complex Agriculture Pre-to Post-Contact 30608 Enclosure Dwelling and Storage Historic 30609 Enclosure Dwelling and Storage Historic 30610 Terrace Agriculture Pre-to Post-Contact 30611 A ricultural Complex Agriculture Pre-to Post-Contact 30612 Lava Blister Refuse Dump Historic The 22 sites were assessed as significant under HAR §13-284-6 Criterion d. Site 30592 (railroad berm) was also assessed as significant under Criteria a and c and was recommended for preservation. Site 30593 (lava tube burial) was assessed as significant under Criterion e and was recommended for preservation. Preservation measures will be outlined in Burial Treatment Plan. The AIS report recommends no further archaeological work for the Site 30591 and for Sites 30594 through 30612. Sufficient information has been collected for these sites to adequately provide information on their age and function. Based on the above information, SHPD's determination is "effect, with agreed-upon mitigation". SHPD concurs with the significance and treatment recommendations. The report meets the requirements specified in HAR §13-276-5. The report is accepted. Please send two hard copies of the document, clearly marked FINAL, along with a copy of this review letter and a text-searchable PDF version to the Kapolei SHPD office,attention SHPD Library(Helen.W.Smith&hawaii. oovv). As stipulated in HAR §13-284-7, when SHPD comments that a project will result in "effect with agreed-upon mitigation commitments", then detailed mitigation plans shall be developed for SHPD review and acceptance prior to project initiation. The agreed upon mitigation commitments are preservation and archaeological monitoring. Pursuant to HAR §13-284-8, SHPD looks forward to receiving a burial treatment plan for Site 30593, an archaeological preservation plan meeting the requirements of HAR 13-279-4 for Site 30592, and an archaeological monitoring plan meeting the requirements of HAR§13-279-4,prior to any County permit issuance. SHPD shall notify the County when our office has reviewed and accepted the archaeological preservation plan and the archaeological monitoring plan, and the interim preservation and the burial treatment measures have been implemented,and the permit application has been reviewed,and permit issuance may occur. Please contact Sean Nleimaile at(808) 933-7651 or at Sean.P.Naleimailekhawaii.gov if you have any questions or concerns regarding this letter. Aloha, '3v,& a., A , W" Susan A. Lebo,PhD Archaeology Branch Chief cc. Glenn Escott, SCS,ggescottkyahoo.com SI'2 AN\E D.CASE .F,.,h,q CHAP R.S(., 1N,•"•• '.,� BOARD OF1.LhT].L\'D\A11lL4L RESOURCES BA<IDY.[GE ,r sass --rp L R4(F5o�cNUTATrP,P— W11MANAGEVE\ G04'ER4i0ROF H.4ti<'AI:I �«• ROBERT R MASIDA FPST DEPUTY M.1(ALEO 3SA\T-EL ell 'Fq DEPLTY 011RECTOR-WATER Q 4 r uZunc e�svL�s RGATUe A.\D=AN RECREA=- HL"BEAL'OFCM%7EYAN= MMM?CS 0a 01 WATER RESOL-RCE MANAGEMEN--T CCU+SERS A NO!%AND COASTAL LAtiT,, STATE OF HAWAII ti4Y SER\ATXi% 1 RESOURCES E>TCRMMEST Syte Of kjew+¢' E-0[\EERITG DEPARTMENT OF LAND AND NATURAL RESOURCES H��'�rR;m' K:IKTOLAR'E ISLAND RE SERVE C-i}LbIISsMN STATE HISTORIC PRESERVATION DIVISION STATE PARKS KAKUHIHEWA BUILDING 601 KAMOKILA BLVD,STE 555 KAPOLEL HAWAII96707 August 19, 2019 Richard Wheelock LOG NO: 2019.01323 Kona Three,LLC DOC NO: 1908JC03 I I I Hualalai St. Hilo, HI96720 Dear Mr. Wheelock, SUBJECT; DRAFT Burial Treatment Plan for Burial Site 450-14-57-30593 Located in Holualoa I" Ahupua`a, North Kona District, Island of Hawaii, TMK: (3) 7-6-021:017. At its monthly meeting on August 15, 2019, the Hawaii Island Burial Council (HIBC) voted on a recommendation to have the State Historic Preservation. Division (SHPD) accept the above DRAFT Burial Treatment Plan. This follows the HIBC determination to preserve in place made at its previous meeting (LOG NO. 2019.01323, DOC NO. 1908JC01). Following the recommendation of the HIBC, the DRAFT Burial Treatment Plan for Burial Site 450-10-57-30593 Located in HC)lualoa 1st Ahupua`a, North Kona District, Island of Hawaii, TAX: (3) 7-6-021:017 is accepted by the SHPD. Please change the title language from "DRAFT Burial Treatment Plan" to "Burial Site Component of a Preservation Plan" and submit hard copies with a copy of this letter and a text-searchable PDF CD to both, our Kapolei and Hilo offices. Should you have any additional questions or concerns, please contact our Hawai`i Island Burial Sites Specialist, Kea Calpito at(808) 430-5709 or via email at Jordan.V.Calpito@Hawaii.gov. Hawaii.gov. Sincerely, a414'(w Mr. Hinano Rodrigues, B.A., J.D. History car Culture Branch Chief CC: Glenn Escott, SCS Inc. SL L4N:�E D.CASE _F„+ p F N t.erqRrFrtsrn< p,WID1'.lGE .R BMRDaJFLIL\[].L\[]rAIC:RALRPSUA-M GO%F R`WR OF HAWAII f.(� C'.RII{LSS'f0\U.\V:.11E RES�C W.:E tlh�'AC£'afE'1I Jq ajS ROBERT{v SLASUDA sJ 1 • �d' .� 1 F[RST DEPLT4' oAk� arm, i spa „g r \i IiALEO CIA\i-EL �{1L I�/ r S i.:'• [JEPLTk DII CTOR wATFR C .�.w•"�^+�f CQl{S{ RC SOAil,u-AND Oi NRER I[ON -XnIEYANCEC cp�BU EAL OF L ON RATER RESOT=MA\'AMME;I C RNSERV ATION A`iD O]ASIAL LANDS STATE OF HAWAII GORSEAZ AlIC�"A RRES ACES E:tVR{E.7EM1I �OE\FE:RL'd 6C]AESTRV.l\'+i NRLU 1.fFE syteof DEPARTMENT OF LAND AND NATURAL RESOURCES HISMRIC'ERE.SER�A770N Fi.SFmN.2.NE I ND RESER\T rOhMMSR. LINT STATE HISTORIC PRESERVATION DIVISION ...TI PARES KAKITHHEWA XUDING 601 KAMOKILA BLVD,STE 555 KAPOLEI,HAWAII 96707 October 30,2020 IN REPLY REFER TO: Michael Yee,Planning Director Log No. 2020.01241 County ofHawai`i Doc. No. 2010NM09 Planning Department Archaeology 101 Pauahi Street, Suite 3 Hilo, HI96720 Dear Michael Yee: SUBJECT: Chapter 6E42 Historic Preservation Review— Archaeological Preservation Plan for Site#50-10-37-30592 Kona Three,LLC Halualoa Property County of Hawaii Change of Zone Application REZ 470,Ord.No. 02-131,RM-5 Zoned Land Halualoa Ahupua`a,North Kona District,Island of Hawaii TNIK: (3)7-6-021:016-019 This letter provides the State Historic Preservation Division's (SIIPD's) review of a request to amend Rezone Ordnance No. 02-131 and the supporting plan titled, An Archaeological Preservation Plana For Site # 50-10-57- 30592 Located in H51ualoa I" Ahipua`a, North Kona District, Island of Hawai`i [TMK.• (3) 7-6-021:016-019] (Escott and Mello,May 2020), SHPD received the submittal on June 1, 2020. Scientific Consultant Services, Inc. (SCS) prepared this archaeological preservation plan (PP) on behalf of the landowner, Dona Three, LLC, as part of mitigation to preserve Site #50-10-37-30592,an historic railroad bents.The landowner plans to develop the property and apply for a County of Hawaii grubbing and grading permit in the future. SHPD Correspondence: 20t 8a In a letter dated May 31,2018,2018(Log No, 2018.01 123, Doc.No. 1805SN05), SHPD accepted the archaeological inventory survey (AIS) completed for a 5.0-acre portion of this project area and reconuneuded an archaeological preservation plan (PP) for Site -950-10-37-30592, a burial treatment plan (BTP) for Site 4 50-1.0-37-30593, and an archaeological monitoring plan (AMP) for proposed development. 2018b In a letter dated July 30, 2018 (Log No. 2018,00878, Doc. No. 1807SN01), SHPD reviewed and had no objection to a request to amend Rezone Ordnance No. 02-131. Additionally, SHPD stipulated the following prior to issuance of any permits: 1, Burial Treaunent Plan(BTP) for Site 30593, 2, Preservation Plan(PP) for Site 30592; 3. Archaeological Monitoring Plan (AMP) for portion of 5-acre AIS project area in proximity to Sites 30592 and 30593; 4, Verification of installation of interim protection measures around Sites 30592 and 30593,and 5. Completion of an AIS for the 63.8-acre portion of the project area within the boundaries of the Hantinatt et al, (1992) Survey. Our records indicate that the Hannnatt et al. (1992) survey report was never revised and accepted and does not meet current HAR §13-276 standards for Michel Yee October 30,2020 Page 2 archaeological inventory surveys. The AIS needs to include a 100% pedestrian survey, identification and update documentation of all archaeological historic properties present, an assessment of their integrity and site significance pursuant to HAR 13-284-6, criteria a-e, as well as site plans for each site, including site boundaries and areas impacted by bulldozing, and photographs of all sites and features. SHPD requests the selected archaeological firm consult with SHPD prior to initiation of the AIS regarding proposed documentation strategy. 2019 In a letter dated August 5, 2019(Log No. 2019.01323, Doc No. 19087Co1), SHPD accepted the BTP (Escort and Mello 2019). The AIS (Escott and Escort 2018) documented twenty-two newly identified historic properties (Table 1). The sites include a pre- and/or early post-Contact lava tube burial, pre- audlor early post-Contact agricultural terraces, and post-Contact walls and enclosures associated with agriculture and/or ranching, and a post-Contact railroad berm. Table 1. Summary of Sites Documented in AIS Site 450-10-37- Tye Function Age 3l?591 A-ncttlluraI Complex Agriculture 11rc-to Post-Contact �0 9 1 Railroad and Bern Transportation Historic 3059.E Lava Tube Burial Pre-to Earl Post-Contact 30594 Agricultural Complex Agriculture Pre-to Post-Contact 30595 Rock Wall Ranching Historic 30596 Possible Hearth Food Preparation Historic 30597 Rock Wall Ranching Historic 30598 Rock Wall Agriculture/Ranching Pre-to Post-Contact 30599 Platform&Enclosure Ranching/Agriculture Historic 30600 Tcrracc Ariculturc Historic 30601 Rock Wnll Ranching Historic 30601 Enclosure Ranchikg/A 'cullurc Historic 3060" ElICIOSLIN Rancl>in /Agriculture Historic 30604 AgiCUltlral Complex Agriculture Prc-to Post-Contact 30605 Rock Wall Ranchin /A riculturc Prc-to Past-Contact 30606 Rock Wall Ranching/Agriculture Prc--to Post-Contact 30607 Agricultural Complex Agriculture Pre-to Post-Contact 30608 Enclosure Dwelling and Storage Historic 30609 Enclosure DwOling and Storage Historic 30610 Terrace Agriculture Pre-to Post-Contact 30611 Agricultural Complex Agriculture Pre-to Post-Contact 30612 Lava Blister Refuse Dump Historic The 22 sites were assessed as significant under HAR §13-284-6 Criterion d. Site# 50-10-37-30592 (railroad berm) was also assessed as significant under Criteria a and c and was recorrnnerided for preservation. Site#50-1.0-3730593 (lava tube burial)was assessed as significant under Criterion a and was reconrrnended for preservation. Preservation measures for Site 950-10-37-30593 are outlined in the BTP. The AIS report recommends no further archaeological work for Site # 50-10-37-30591 and for Sites # 50-10-37-30594 through #50-10-37-30612. Sufficient information has been collected for these sites to adequately provide information on their age and function, The current PP for Site # 50-10-37-30592 indicates the site "will be preserved with are provision that it may be breached for the purposes of access(Escott and Mello 2020;37)" SBPD stipulates the following need to be completed prior to submittal of revised PP; 1. SHPD acceptance of the draft Escott and Escott(2020)AIS for the 63.8-acre portion of the project area and incorporation of any agreed-upon preservation sites or portions of sites into the revised PP. Note for example that Site # 50-10-37-030592 occurs in both the 63.8-acre and 5.0-acre portions of the overall prvoi ect area, Michel Yee October 30,2020 Page 2 2. Insertion into the PP of text and permit plans detailing the location and extent of die proposed breach of Site#50-10-37-30592; 1, A permit application for the breach work and a SHPD HRS 6E Submittal.Form for die project; and 4, Address the revisions specified in the Attachment(below). Please highlight all revisions in the revised draft PP, include with the revised plan a list of the requested revisions, the actions taken, and the page number in the revised text where each change can be found. To facilitate review of the revised plan, please submit the HRS Submittal Fee Form, a letter sunnnarizing the revisions, and a copy of this letter electronically to DLNR.Intake.SHPD(a-hawaii.gov, SHPD shall notify the County when the Escott and Escott(20201) AIS for the 63,3-acre project area is accepted and,subsequently, when the PP is accepted, and die permit issuance process may proceed. Please contact Nicole A. Mello, Hawaii Island Archaeologist IV, at Nicole.Mello( hawaii.gov for matters regarding archaeological resources or this letter. Aloha, liwlf f• Alan S.Downer, PhD Administrator,State Historic Preservation Division Deputy State Historic Preservation Officer cc: Glenn Escott, Scientific Consultant Services,g_gescott(a,7yahooxom Richard A. Wheelock,richarQ')eastwestrealty.ore Sean Naleimaile, SHPD, sean.p.naleimaile4)lnawaii.gov Attachment Counnents and Concerns: Are Archaeological Preservation Plain for Site 450-10-57-30592 Locoed in Holualoa 1st Ahupua`a,North Kona District, Hawai`i Island TMK: (3) 7-6-021:016-019 (Escott and Mello,May 2020). General 1. The current preservation plan only includes the 63.0-acre project area. The AIS for the 63.0-acre portion of this project is wider SHPD review and needs to be accepted before the PP can be accepted. Additionally, the 5.0-acre portion that includes the railroad needs to be included in this project area For the preservation plan The preservation plan should then combine both project areas and incorporate all sites/portions of sites for preservation. 2. Please wait to revise the PP until the AIS has been accepted because SHPD may request additional things to be added into this PP. 3. Additionally,please check throughout the plan to make sure it includes both portions of AIS project areas. For example,the title should include Holualoa 1st and 2",maps, etc.. Introduction 4. Title Site 450-10-57-30592 and first page Site 950-10-37-30592 are not the same. Please correct site#. 5. (Pg. 1)Please include the project area in acres. Since this plan will include both the 5,0 acre project area and the 63-acre please include this here. Also it would be helpful to include a short summary that the two project areas are part of two separate AISes but the site for preservation spans both the project areas and. therefore this plan will incorporate both those. Also both project areas are part of the same project (change of zone). 6. (Pg. IT2) Small typo in first sentence please add"to-"...contracted SCS to produce..:- 7. (Pg, 1)Please include in the introduction the size, in acres, of the current project area. Background S. (Pg. 611) Small typo in sentence 2. Punalu`u should not include diacritical because Sato et al, 1973 does not use them.Also,citation should include "et al," Michel Yee October 30,2020 Page 2 9. (Pg.8¶3)Honaunau=Hanaunau, please check throughout document. 10. (Pg.9 11) Citations for the last part of the paragraph'?If it is+Gordy please clarify, 11. (Pg.9¶3) Please include a citation for the last sentence,if same as previous please note. 12. (Pg. 10�12)Please include citations for sentences 2-5.If this information is all one source please clarify. 13. (Pg. 19�iI)Please write out acronyms when first mentioned. 14. (Pg,20 T,4)Please include full site#for Site 6661, 15. (Pg. 19-23)Please ensure the archaeological firm names that conducted the previous archaeological work are mentioned in the descriptions. 16. (Pg. 22 16) Small typo in first sentence "...conducted and archaeological..." to "...conducted an archaeological..." 17. (Pg. 24 14) Was this burial site identified during some sort of construction activities? This paragraph indicates the burials were removed prior to 1983 but the AIS occurred in 1992 so it is a little unclear about when and how the burials were 'identified. 18. (Pg.2813)Please rewrite the second to last sentence to reflect that the plan referenced is the current plan. 19. (Pg, 31 ¶2) Please reword the second pert of the second sentence for clarity. It says "...and one Site former burial site...'Maybe just add an"is a"to make it snore of a complete statement. 20. (Pg.37 T2) Sinall typo in the third sentence"proviso"to"provision" 21. (Pg. 37) Need clarity on the breaching for access. If this is going to happen for sure, how much of the site will be breached? The map shows potential breaching in two locations but it is not clear how much of the site will be destroyed in the process. The plan should include specific distances such as "a 20-foot breach in the northern location and a 10-foot breach will occur on the south end" or"a maximum of 30 feet will be breached in two locations."How will the breaching be recorded? There should a detailed description on the acceptable size breach for the site because the current mention of breaching is open-ended and can lead to misinterpretations regarding what is acceptable for destroying a portion of the site that is recommended for preservation. SL L4X:�E D.CASE _F„+ p F N [.ELg1RPERSVF DAV[D Y.!GE �� aM6MN-L M ago tin L:aAL reesor.xczs G0%FRVOROFEiAWA31 f.(� -+t95p � 'f 3 nnaiLsssoa a�a.nz£.R RESOLACE tL�ME!:I 1q sJ ROBERT 6.LL4SL7]A FMSIDEPL'Tl' oAk� arm ryd ,-'fg YYY f. \i FULF0-MAN L-EL �{1L I�/ r S i.`',•( DEPLTk�II2E TC R WRIER ,. l -ATIC RFSR ROES � .....•"�✓ 80ATl.�O-AND PCE�N REl.REAiTOti � ^+ K31EAL OF LEA1T�'A 1 510'.0 ON W)LTF F MC RCE MMIAMME;I Lu��LRl'ATR NAND COASI,5L LA\LS STATE OF HAWAII 'I4,.ATII DBE LftL 5ENFORCEMENT �aC FF LAC 'fRESTBV.L\V ILILDLGl syt@Of a a+ DEPARTMENT OF LAND AND NATURAL RESOURCES IMMRIC PRE SEEVATIU, K..��AT ISL4.L RESER\T COhMMSi. LINT STATE HISTORIC PRESERVATION DIVISION .TRTE PAR1:5 KAKITHHEWA BTUDING 601 KAMOKILA BLVD_STE 555 KAPOLEI.HAWAII 96707 October 15,2021 IN REPLY REFER TO: Zendo Kern, Planning Director Project No.2020PR32834 County of Hawaii,Planning Department Submission No. 2020PR32834.005 101 Pauahi Street, Suite 3 Doc_No, 21 IONMO5 Hilo_Haivai`i 9+6720 Archaeology Plannin d1awahcountv.gov Dear Zendo Kern: SUBJECT: Chapter 6E-42 Historic Preservation Review— County of Hawaii Change of Zone Application,REZ 470, Ord.No.02-131,RNI-5 Zoned Land Kona Three,LLC Holnaloa Property Archaeological Inventory Survey Holualoa Ahupua`a,North Kona District,Island of Hawaii TMK: (3)7-6-021:016-019 This letter provides the State Historic Preservation Division's (SHPD's) review of a request to amend Rezone Ordnance No. 02-131 and the supporting draft report titled, Archaeological Inventory Sun?ev Report for 76.121 Acres Located in 110taloa 1st Ahupua`a, Alorth Kona District, Hmtpoi`i Island. Hairai`i JTIX. (3) 7-6-021:016- 019](Escott and Escott. August 2021). Table 1 sunnnarizes the submittals received for the subject project. Date Received Project No. or Submission No. Materials Received March 3,2021 2020PR32834(PreviOLisly Log No.2020.00727) Original Submittal with Draft AIS May 7,2021 2020PR32834,002 SIHP Request Form May 12,2021 2020PR328.34,003 Revised AIS 1 and Response July 28, 2021 2020PR32834,004 Revised AIS 2 and Response October 11,2021 2020PR32834,005 Revised AIS 3 and Response Scientific Consultant Services, Inc. (SCS) completed the AIS of approximately 76.121 acres at the request of the applicant, Kona Three, LLC and Richard Whcelock (owner), and in response to a SHPD letter dated July 30, 2020 (Log No. 2018.00878, Doc, No, 1807SN01). The landowner plans to apply for a County of Hawaii grubbing and grading permit in support of proposed development of the property. Pertinent SHPD Correspondence: 2018a In a letter dated May 31, 201S (Log No. 2018,01123, Doc, No, 1805SN05), SHPD accepted the AIS completed for a 5.0-acre portion of the overall project area and agreed to mitigation commitments in the form of an archaeological preservation plan(PP) for Site# 50-10-37-30592,a burial treatment plan (BTP) for Site # 50-10-37-30593, and an archaeological monitoring plan (AMP)for the proposed development. 2018b In a letter dated July 30. 2018 (Log No. 2018.00878, Doc. No. 1807SN01), SHPD reviewed and had no objection to a request to amend Rezone Ordnance No, 02-131. Additionally, SHPD stipulated the following needed to be completed prior to issuance of any permits: 1. Burial Treatment Plan for Site#50-10-37-30593; 2. Preservation Plan for Site#50-10-37-30592, Zendo Kern October 15,2021 Page 2 3. Archaeological Monitoring Plan for the portion of the 5-acre AIS project area in proximity to Sites#50-10-37-30592 and 4 50-10-37-30593; 4. Verification of installation of interim protection measures around Sites #SO-10-37-30592 and # 50-10-37-30593;and 5. Completion of an AIS for the 63.8-acre portion of the project area within the boundaries of the Hamniatt et at. (1992) survey. Our records indicate that the Hanunatt et al. (1992) survey report was never revised and accepted and does not meet current HAR §13-276-5 standards for archaeological inventory surveys. The AIS for the 63.8-acre portion needs to utchide a 100% pedestrian survey, identification and updated documentation of all archaeological historic properties present, an assessment of their integrity and site significance pursuant to HAR §13- 284-6, Criteria a-e, as well as site plans for each site, including site boundaries and areas impacted by bulldozing, and photographs of all sites and features. Lastly, SHPD requested the selected archaeological firm consult with SHPD prior to initiation of the AIS regarding proposed documentation strategy. 2020a In a letter dated October 30, 2020 (Log No. 2020.01241, Doc. No. 2010NM09), SHPD reviewed the plan titled, An Archaeological Preservation Plan for Site # 50-10-57-30592 Located in H,5hialoa 1-Alnipua`a, North Iona District,Island of Hawai`i[TMIK: (3) 7-6-021:016-019](Escott and Mello, May 2020). SHPD stipulated the fallowing needed to be completed prior to submittal and acceptance of a revised PP: 1. SHPD acceptance of the draft Escort and Escort (2020) AIS for the 63.8-acre portion of the project area and incorporwion of any agreed-upon preservation sites or portions of sites into the revised PP,Nate for example that Site#50-10-37-030592 occurs inboth the 63.8-acre and 5,0-acre portions of the overall project area; 2. Insertion into the PP of text and permit plans detailing the location and extent of the proposed breach of Site#50-10-37-30592; 3. A permit application for the breach work and a SHPD HRS 6E Submittal Form for the project: and 4. Address the revisions specified in the Attachment. 2020b In a letter dated November 19,2020(Log No. 2020.00727, Doc,No 2011NM04), SHPD requested revisions to the Escort and Escott(March 2020) AIS report. Previous archaeological studies within the project area consist of a reconnaissance survey (Hanimatt and Folk 1983) and two AIS (HannYtatt et al. 1984: Hanimatt et al. 1992)conducted in TMK: (3) 7-6-021:016 and 017, and a field inspection of the current project area(Escott 2016). SHPD did not accept the Hammatt et al.(1984)AIS as it did not meet the standards(August 25, 1992,Log No,6174, Doc.No.3524c;and October 5, 1992, Log No, 6482, Doc, No, 3542c). The AIS identified 21 archaeological sites inside the current project area: Sites 50-10-37-10011, 50-10-37- 10012, 50-10-37-10013, 50-10-37-10015, 50-10-37-10017, 50-10-37-10018, 50-10-37-10019, 50-10-37-10020, 50- 10-37-10031, 50-10-37-10033, 50-10-37-10034, 50-10-37-10049, 50-10-37-10067, 50-10-3 7-10068, 50-10-37- 10069, 50-10-37-10070, 50-10-37-10071, 50-10-37-10072, 50-10-37-10073, 50-10-37-10074, and 50-10-37-1007 and two bulldozed modern planting terraces. The total project area was 174 acres of which 66.039 acres are within the current overall project area. Site I0012 consisted of two burials that were minterred outside the project area. Excavated sites in the current project area included Sites 10011, 10012, 10013, 10019, 10067, 10068, 10069. 10070, 10072, 10073,and 10074. No correspondence associated with the Hammatt et aL(1992) project was located during preparation of this review. As such,it is unknown at this time whether Hammatt et al. (1992) assessed the archaeological sites for significance, and whether reconnnendations were made regarding which sites were adequately docwnented, requiring no further work, and which retained potential for further documentation through mitigation including archaeological monitoring or preservation. Hanma.att and Shideler (2007) submitted additional site documentation in the form of a letter to SHPD for Sites 10011, 10012, 10031, 10049 and 10071. Site maps and photographs were not provided for all sites. SCS conducted an archaeological field inspection (Escort 2016) of the current project area to relocate the sites identified during the Harmnatt et al. (1992) AIS,to assess their current condition and the adequacy of the Hammatt Zendo Kern October 15,2021 Page 3 et al, documentation.The field inspection did not include completing new documentation in the form of draw-ing site maps or taking photographs of sites where such documentation was not recorded by Hammatt et M. (1992),althou&h such documem;i€inn is re uimd to meet the minimum AIS standards as defined in HAR §13-276, The current AIS (Escott and Escott, August 2021) indicates that the project area was bulldozed for commercial agriculture in the 1950s. Consultation occurred with Gregg Kashiwa who was the property manager for parcels 016 and 017 in the 1980s. Kashiwa indicated the project area was already bulldozed at that time but was fmiliar with the historic features on the property. SCS also contacted Shane Nelson, an Office of Hawaiian Affairs (OHA) representative,but received no response. The fieldwork component of the Escott and Escott (August 2021) AIS was conducted throughout 2020. The project included a 100% surface survey with site recordation, GPS, photography, and subsurface excavation with documentation. A total of 16 sites and one isolated find(IF-1) were identified during the AIS (Table 1). Two sites and a petroglyph(Site 50-10-37-31181, Site 50-10-37-3 1 182, and 50-10-37-31254) were newly identified and the remaining fourteen sites were previously documented (Hammatt et al. 1992), Five previously identified sites were determined no longer present (Site 50-10-37-10012, Site 50-10-37-10017, Site 50-10-37-10033, Site 50-10-37- 10049, and Site 50-10-37-10071). Site 50-10-37-10015 was determined to be a modern bulldozer road segment and therefore it is not an archaeological site. The Site 50-10-37-10012 burial (MNI =2), along with the entirety of the burial crypt and all associated features, were disinterred during the Hannnatt et al. (1992) project and reinterred outside the project area in 1993. The reinterment was conducted in consultation with the Havvai`i Island Burial Council and Marc Smith from SHPD. A letter dated February 8, 1993, from Gregg Kashiwa (Cultural Surveys Hawaii,Inc.)to SHPD,provides additional details regarding the burial site. Site 50-10-37-10020 and Site 50-10-37- 10034 were detemlined to be natural geological features. The sites include pre-Contact to post-Contact enclosures, platforms,mounds, lava tubes,walls, a railroad berm, and complexes. Two sites (Site 50-10-37-1001I and Site 50- 10-37-10073)were excavated during the current AIS. Table I.Arch rreolo ical sites documented ring the current AIS. SLIP# Site Description Function Temporal Significance*. Mitigation (50-10-28 Association -1001 1 Platform AL,,iicuit oral C1c�irhw, Pi-c-Contact d 1FW -10012. Former Burial Platfonu Burial Pre-Contact No longer 1\FW si ificant -10013 Enclosure and Lava Tube Habitation Pre-Contact d NFW -10018 Enclosure Remnant 1-1gdciilture Historic d NFW -10019 Ronk Mounds A�odculwral Clearing Historic d NFW -10031 Filclosire )Xall ALTictilturc Historic d NFW -10067 Terraces Habitation Pre-Colitact d NFW -10068 Enclosure Habitation Pre-Contact d NFW -10069 Modified Bluff/Platform Habitation Historic d NFW -10070 U-shaped Enclosure Agriculture Historic d NFW -10072 Complex Agricultural Clearing Pre-Contaci d NFW -10073 Complex Ranching/Agriculture Historic d NFW -10074 Enclosure Coffee Work Shed Historic d NFW -10075 Enclosure Pig Pen Historic d NFW -30592 Railroad Bern Transportation Historic a, c,d P -311.81 Enclosure Coffee Work Shed Historic d _FVti -31182 Rock Walls Ranching and Historic d NFW Agriculture -31254 Petroglyph Marker Pre-Contact d, e P *No Further Work(NFW),Preservation(P) The 18 sites were assessed as significant under HAR §13-284-6 Criterion d. Site 50-10-37-30592,the railroad berm, was also assessed as significant under Criteria a and c and was recommended for preservation. Site 50-10-37-31254, a petroglph, was also assessed as significant under Criterion a and was recommended for preservation. Site 50-10- 37-10012 is a former burial site where the disposition (burial and associated burial crypt and features) were relocated. Thus,there are no known human skeletal remains left. Nevertheless,it is recommended that this former Zendo Kern October 15,2021 Page 4 burial site be flagged for preesrvation in the form of avoidance. The previous site location will be monitored if construction activities occur near that location. The report reconunends no further historic preservation work for the remaining sites. SHPD agrees with the site integrity and significance assessments for all 18 sites. SHPD's project effect deterrnination is "Effect, with agreed upon mitigation commitments" and SHPD agrees that the lb sites recommended for no further work have been adequately documented. SHPD agrees with the preservation of Sites 50-10-37-30592 and 50-W-37-31254 and additional mitigation in the form of archaeological monitoring during initial ground disturbance for the entire project area. The Escott and Escott (August 2021) AIS report addresses the concerns raised in our earlier correspondence and satisfies the requirements of HAR §13-276-5. It is accepted. Please send two hard copies of the document,clearly marked FINAL, along with a text-searchable PDF copy of the document and a copy of this acceptance letter to the Kapolei SHPD office, attention SHPD Library. Additionally, please upload a text-searchable PDF version of the document to HICRIS Project No. 2.020PR32834 using the Project Supplement option and send a text-searchable PDF copy of the AIS report to lehua.k.soaresCirlhawaii.gov. SHPD requests the following be submitted for SHPD review and acceptance prior to permit issuance: 1. An archaeological monitoring plan (AMP) for all initial ground disturbing activities that meets the requirements of HAR §13-2794, 2. An archaeological preservation plan(PP) for Site 50-10-37-30592 and Site 50-10-37-31254 that meets the requirements of HAR §13-277;and 3. Written and photographic documentation verifying implementation of interim protection measures for Sites 50-30-37-30592 and 50-10-37-31254, Please submit the plans and the interim protection documentation, along with the required review fees for the AMP and PP to HICRIS Project No. 2020PR32834 using the Project Supplement option. SHPD shall notify the County when the mitigation plans are accepted, and the permit issuance process may proceed. Please contact Nicole A. Mello, Historic Preservation Archaeologist IV, at Nicol e.Melloglrawaii.gov, for matters regarding archaeological resources or this letter. Aloha, 4 17�kvlw Alan S. Downer, PhD Achninisrrator,State Historic Preservation Division Deputy State Historic Preservation Officer cc: Glenn Escoa, SCS,ggescott0yahoo.com Richard A. Wheelock,richard&eastwestreaU.org Sean Naleimaile, SHPD, sean.p.naleimaileC hawaii.gov SCIFNTIFIC CONSUIXAWT SERVICES InC. an 1357 Kapi`olani Blvd., Suite 850 Honolulu,HI 96814 Hawaii Island Office: PO Box 155 Kea`au,HI 96749 Susan Lebo, Ph.D. 6/15/2022 Archaeology Branch Chief DLNR-SHPD In Reply to: 601 Kamokila Blvd., Rm. 555 Project No. 2020PR32834 Kapolei, HI 96707 Log. No. 2020.01241 808-321-9000 Doc. No. 2010NM09 susan.a.lebo@hawaii.gov Submittal of Revised Report: Chapter 6E-42 Historic Preservation Review--Archaeological Preservation Plan for Site # 50-10-37-30592 and Site # 50-10-37-31254 Kona Three, LLC Holualoa Property Holualoa Ahupua`a,North Kona District, Island of Hawaii TMK: (3) 7-6-021:016-019 Aloha e Susan: SCS has revised the draft archaeological preservation plan (PP)referenced in the header based on the comments provided in the attachment received with your letter dated October 30, 2020. All of the review comments were addressed and requested revisions and additions were made. The Attachment below includes a description of how SCS addressed each comment. Revisions made in the revised preservation plan are highlighted yellow. Thank you in advance for your review and approval. SHPD stipulated the following be completed prior to submitting the revised draft PP: 1. SHPD acceptance of the draft Escott and Escott (2020) AIS for the 63.8-acre portion of the project area and incorporation of any agreed-upon preservation sites or portions of sites into the revised PP. Note for example that Site # 50-10-37-030592 occurs in both the 63.8-acre and 5.0- acre portions of the overall project area; SCS Response: The AIS report has been accepted by SHPD. 2. Insertion into the PP of text and permit plans detailing the location and extent of the proposed breach of Site # 50-10-37-30592; SCS Response:Revised as requested(see below). Wheelock Holualoa PP-1 RTC June 15,2022 Page 2/2 3. A permit application for the breach work and a SHPD HRS 6E Submittal Form for the project; and SCS Response: As we discussed by phone, and I summarized in my email (both on 611412022), the owner cannot submit a permit application for the RR berm breach and utilities trenching until DWS approves the waterline plans, and DWS will not review the plans until SHPD approves the PP. As you mentioned Susan, the solution might be that SCS submit the revised draft PP without a permit application, and SHPD can issue an acceptance letter with the provision that states County should let SHPD know if the breach application plans change or are different than those in the PP. In that event, SHPD will review the permit application plans and will advise County if the revised plans are acceptable. 4. Address the revisions specified in the Attachment (below). SCS Response:All revisions and additions were made to the PP, as requested(see below). Sincerely, hi Glenn G. Escott, MA Hawaii Island Operations Manager Scientific Consultant Services, Inc. ggescott@yahoo.com 808-938-0968 Uploaded to HICRIS: Revised draft archaeological preservation plan. Attachment Comments and Concerns:An Archaeological Preservation Plan for Site 950-10-57-30592 Located in Holualoa 1stAhupua`a, North Kona District, Hawai`i Island TMK: (3) 7-6-021:016-019 (Escott and Mello, May 2020). General 1. The current preservation plan only includes the 63.0-acre project area. The AIS for the 63.0-acre portion of this project is under SHPD review and needs to be accepted before the PP can be accepted. Additionally,the 5.0-acre portion that includes the railroad needs to be included in this project area for the preservation plan. The preservation plan should then combine both project areas and incorporate all sites/portions of sites for preservation. Revised as requested. 2. Please wait to revise the PP until the AIS has been accepted because SHPD may request additional things to be added into this PP. Both AIS report have been accepted. The SHPD AIS approval letters are inserted as Appendix A to the preservation plan. 3. Additionally,please check throughout the plan to make sure it includes both portions of AIS project areas. For example, the title should include Holualoa 1 st and 2nd, maps, etc.. Revised as requested. Introduction 4. Title Site 950-10-57-30592 and first page Site 950-10-37-30592 are not the same. Please correct site#. Revised as requested. 5. (Pg. 1) Please include the project area in acres. Since this plan will include both the 5.0 acre project area and the 63-acre please include this here. Also it would be helpful to include a short summary that the two project areas are part of two separate AISes but the site for preservation spans both the project areas and therefore this plan will incorporate both those. Also both project areas are part of the same project(change of zone). Revised as requested. See page 1,paragraph 3. The overall project area for both AIS studies, parcels 016—019,totals 76.121-acres. 6. (Pg. IT2) Small typo in first sentence please add"to" "...contracted SCS to produce..." Typo corrected. 7. (Pg. 1) Please include in the introduction the size,in acres, of the current project area. Revised as requested. See page 1,paragraph 3. The overall project area for both AIS studies, parcels 016—019,totals 76.121-acres. Background 8. (Pg. 6¶1) Small typo in sentence 2, Punalu`u should not include diacritical because Sato et al. 1973 does not use them. Also, citation should include"et al." Revised as requested. See page 6,paragraph 2. 9. (Pg. 8¶3)Honaunau=Honaunau,please check throughout document. Two corrections made. Page 9,paragraphs 1 and 3. 10. (Pg. 9¶1) Citations for the last part of the paragraph? If it is Cordy please clarify. Revised as requested. 11. (Pg. 9¶3)Please include a citation for the last sentence, if same as previous please note. Revised as requested. 12. (Pg. 10¶2)Please include citations for sentences 2-5. If this information is all one source please clarify. Revised as requested. 13. (Pg. 19 ¶1)Please write out acronyms when first mentioned. Full name for PHRI was added. 14. (Pg. 20 ¶4)Please include full site#for Site 6661. Site prefix added. 15. (Pg. 19-23)Please ensure the archaeological firm names that conducted the previous archaeological work are mentioned in the descriptions. Revised as requested. 16. (Pg. 22 ¶6) Small typo in first sentence "...conducted and archaeological..."to "...conducted an archaeological..." Typo corrected. 17. (Pg. 24¶4) Was this burial site identified during some sort of construction activities? This paragraph indicates the burials were removed prior to 1983 but the AIS occurred in 1992 so it is a little unclear about when and how the burials were identified. Text was added to page 24 stating that: The AIS field work was conducted during the first few months of 1983. The burials at Site 10012 were removed and reinterred off-project in 1983, after initial field work was completed, and after consultation with and approval from DLNR and County Planning to reinter the burials elsewhere. 18. (Pg. 28 ¶3)Please rewrite the second to last sentence to reflect that the plan referenced is the current plan. Revised as requested. 19. (Pg. 31 ¶2)Please reword the second part of the second sentence for clarity. It says "...and one site former burial site..." Maybe just add an"is a" to make it more of a complete statement. Revised as requested. 20. (Pg. 37¶2) Small typo in the third sentence "proviso'to "provision". Revised as requested. 21. (Pg. 37)Need clarity on the breaching for access. If this is going to happen for sure,how much of the site will be breached? The map shows potential breaching in two locations but it is not clear how much of the site will be destroyed in the process. The plan should include specific distances such as "a 20-foot breach in the northern location and a 10-foot breach will occur on the south end" or"a maximum of 30 feet will be breached in two locations." How will the breaching be recorded? There should a detailed description on the acceptable size breach for the site because the current mention of breaching is open-ended and can lead to misinterpretations regarding what is acceptable for destroying a portion of the site that is recommended for preservation. Revised as requested. See page 40,paragraph 2. The revisions include breach,road and water trench dimensions,waterline trench typical cross section figure, as well as a provision that the ground disturbance for the breaches will be monitored in accordance with a SHPD-approved AMP to be written. Archaeological monitoring for the breaches will include scale profile drawings of one end of the berm at each breach, and photographs of both ends of the berm at both breaches. GPS points will be taken at both ends of the berm at each breach.